Iran Sanctions

The Iran program is the oldest and, as of 2026, the most active of the U.S. sanctions regimes administered by the Treasury Department’s Office of Foreign Assets Control. It is comprehensive rather than list-based: with narrow exceptions, U.S. persons may not deal with Iran at all, and the exceptions have been narrowing fast.

This page explains what the program prohibits, what changed during the 2026 escalation, and what routes are available if you or your company is caught by it.

The Iranian Transactions and Sanctions Regulations

The core rules sit at 31 CFR part 560, the Iranian Transactions and Sanctions Regulations, usually shortened to the ITSR. OFAC reissued them in their current form in October 2012 and has amended them repeatedly since. They implement a stack of executive orders — among them E.O. 12957, E.O. 12959, E.O. 13059, E.O. 13599, E.O. 13846, and E.O. 13902 — along with several statutes.

Two features of the ITSR matter more than the rest.

It is comprehensive. Most OFAC programs work from a list: you check whether a counterparty appears on the SDN List, and if not, you proceed. Iran does not work that way. The baseline is that trade and financial dealings with Iran are prohibited for U.S. persons, and you need to find an affirmative authorization before you act.

It reaches beyond U.S. borders. Section 560.215 applies to entities owned or controlled by U.S. persons and established outside the United States, and it makes the U.S. parent civilly liable when such an entity violates the prohibition. OFAC applied that provision in its August 2026 settlement with Rice Lake Weighing Systems, where an Italian subsidiary sold through a distributor in Dubai to an Iranian end user.

What the Iran Program Prohibits

Broadly, and subject to authorizations, U.S. persons may not:

• Export, reexport, sell, or supply goods, technology, or services to Iran, directly or indirectly through a third country.
• Import Iranian-origin goods or services into the United States.
• Engage in transactions involving property in which the Government of Iran has an interest.
• Deal with any person blocked under the Iran authorities, including entities caught by the 50% Rule.
• Facilitate a transaction by a foreign person that a U.S. person could not do directly — approving, financing, or arranging it counts.

Civil liability runs on a strict liability standard. OFAC does not have to show you intended to break the law, only that the transaction happened. Intent matters to the size of a penalty, not to whether there was a violation. Criminal liability under 50 U.S.C. 1705 is different: there the government must prove willfulness.

The 2026 Escalation

The Iran program changed more in 2026 than in the preceding decade. Anyone relying on an authorization should check its current status rather than assume it survived.

We covered the oil and shipping sequence in OFAC Revokes Iran General License X, and the remittance suspension in OFAC Suspended the Iran Personal Remittance License.

General Licenses Suspended on August 24, 2026

OFAC stayed five authorizations indefinitely, effective August 24, 2026. General License BB authorized only the wind-down of transactions previously authorized under them, through 12:01 a.m. EDT on September 8, 2026.

Anything within those categories now requires a specific license from OFAC.

Secondary Sanctions and Non-U.S. Companies

The Iran program reaches foreign companies that never touch a U.S. person or a U.S. dollar. Under E.O. 13902, the Treasury Secretary can determine that sanctions apply to whole sectors of the Iranian economy, and anyone found to operate in a covered sector becomes exposed to designation.

On August 24, 2026, OFAC determined that E.O. 13902 reaches the aviation, digital asset, gold, shipping, and technology sectors of the Iranian economy, adding them to sectors determined earlier, including construction, mining, manufacturing, and textiles.

Separately, OFAC’s updated alert on the Strait of Hormuz treats payments made to secure vessel passage as presumptively benefiting the IRGC, which carries secondary sanctions exposure. That alert accompanied the designation of entities involved in coercing vessels into buying “insurance” for safe passage.

For a non-U.S. business, the practical exposure is rarely a fine. It is designation to the SDN List, or the loss of correspondent banking access — either of which can end the business.

If You Are Caught by the Iran Program

Different problems take different routes.

You were designated to the SDN List. The route off is a petition for administrative reconsideration under 31 CFR 501.807, filed through OFAC’s Reconsideration Portal, showing the basis for designation never applied or no longer exists. If that fails, the designation can be challenged in federal court. See our work on SDN List removal and OFAC litigation, and the Zadornov delisting as a worked example of a two-stage strategy.

Your funds were blocked or your transfer was rejected. These are different outcomes with different remedies. Blocked funds sit in an interest-bearing account and may be released through an unblocking application. Start with our guide on what to do when OFAC blocks your funds.

You need to do something the regulations prohibit. That means a specific license application through OFAC’s licensing portal — the only route now open for personal remittances, academic exchanges, conferences, and sports activities involving Iran. See OFAC licensing.

You received a subpoena or a request for information. OFAC is gathering facts, which is not the same as a charge, but the response shapes everything that follows. See administrative subpoenas and OFAC enforcement and investigations.

You found a violation in your own operations. A qualifying voluntary self-disclosure cuts the base civil penalty for non-egregious conduct in half and weighs as a mitigating factor. See voluntary self-disclosures.

Our Iran Coverage

• OFAC Suspended the Iran Personal Remittance License — August 2026
• OFAC Revokes Iran General License X: The GL X1 Wind-Down and the Shamkhani Shipping Sanctions — July 2026
• Rice Lake Weighing Systems Settles with OFAC Over Its Italian Subsidiary — August 2026
• Exodus Movement Settles with OFAC for $3.1 Million Over Iran Sanctions Violations — March 2026
• Do Sanctions Work? A Conversation on Iran and Beyond — August 2026
• Sanctions Year in Review 2025 — comparative analysis including Iran

Talk to an Iran Sanctions Lawyer

Sanctions Law Center is a Washington, DC firm practicing exclusively in OFAC sanctions. Our founder has written and spoken extensively on the Iran program, and the firm represents individuals, families, and companies on both sides of it — those seeking authorization and those defending against enforcement.

If a transfer of yours has been stopped, you have been designated, or you need a license to do something the ITSR prohibits, contact us for a free case evaluation, or call +1 (202) 888-9011.

This page is general information, not legal advice. The Iran program is changing quickly; confirm the current status of any authorization before relying on it.